11/07/2005
Upon receiving a non-local check, we attempted to call for check verification. The bank we spoke with said that due to the USA PATRIOT Act, they were unable to verify funds, and that we would have to deposit the check and wait for it to clear. I was unaware of this and was wandering where it's stated in the USA PATRIOT Act.
10/03/2005
We have a customer (a funeral home) that would like to open numerous "pre-need" accounts for their customers. The owner of the funeral home has his customer's name and social security number, but in a lot of cases, no identification (some of his customers are in nursing homes and the accounts are requested by family members.) The accounts would be titled "ABC Funeral Home FBO John Doe," using the person's SS#. Our question: To comply with the USA PATRIOT Act and our CIP policy, how do we positively identify the customer if they do no personally come into our bank AND if the funeral home does not have identification on file for them to present to us at the time of account opening? Since the account is set up in the name of the funeral home for benefit of the customer, as long as we positively identify the funeral home as a business and the funeral director as the signer of the account, have we met the requirements for positively identifying our customer? We hate to refuse to open the accounts but we don't want to violate our own CIP policy which states that all accountholders must present valid ID in person. Help please!
06/20/2005
Section 355 of the USA PATRIOT Act. Are we required to file a SAR when we have uncovered discrepancies in an individuals employment application?
05/16/2005
Regarding FinCen 314 (a) requests. If we have a system that is able to keep a database of all FinCen inquiries and scan new accounts to that list, is that allowed? Or are we supposed to just scan our current clientele and not worry about any new accounts after the check date?